«Denying a lawyer's right to free
expression on behalf of a client in a court of law in favour of a vague definition of civility and its application after the fact fetters and chills the lawyer's ability to engage in vigorous advocacy,» Groia argues in his factum, «in turn damaging the
public interest, as well as infringing [on] the ability of an accused or client to make full answer and defence in a
judicial proceeding.»